# Kadrey v. Meta

> Source: https://aiwiki.ai/wiki/kadrey_v_meta
> Updated: 2026-05-19
> Categories: AI Incidents & Controversies, AI Policy & Regulation, Meta AI
> From AI Wiki (https://aiwiki.ai), a free encyclopedia of artificial intelligence. Quote with attribution.

# Kadrey v. Meta Platforms

**Kadrey v. Meta Platforms, Inc.** is a putative class action lawsuit filed in 2023 by a group of book authors against [Meta](/wiki/meta) Platforms, Inc., alleging that Meta infringed their copyrights by training its [LLaMA](/wiki/llama) family of large language models on books downloaded from shadow libraries such as LibGen, Anna's Archive, Z-Library, and Bibliotik. The case is captioned **Kadrey et al. v. Meta Platforms, Inc.**, Case No. 3:23-cv-03417-VC, and is pending in the U.S. District Court for the Northern District of California before Judge Vince Chhabria.[^1][^2]

The lawsuit became one of the most closely watched copyright cases of the [generative AI](/wiki/generative_ai) era. On June 25, 2025, Judge Chhabria granted Meta partial summary judgment, holding that Meta's use of the named plaintiffs' books to train Llama qualified as fair use under the specific record presented. The ruling, however, was unusually qualified: the judge wrote that his decision did "not stand for the proposition that Meta's use of copyrighted materials to train its language models is lawful," but only that "these plaintiffs made the wrong arguments and failed to develop a record in support of the right one."[^3][^4]

The case continues in 2026 on separate distribution-rights claims related to Meta's torrenting of pirated book files. It is regularly discussed alongside [Bartz v. Anthropic](/wiki/bartz_v_anthropic), [Concord Music Group v. Anthropic](/wiki/concord_v_anthropic), and [New York Times v. OpenAI](/wiki/new_york_times_v_openai) as part of the first wave of generative-AI copyright litigation in the United States.[^5][^6]

## Background and parties

### Plaintiffs

The action was initiated by three named plaintiffs:

- **Richard Kadrey**, an American author known for the *Sandman Slim* series of urban fantasy novels. According to the complaint, Kadrey resides in Pennsylvania and owns registered copyrights in several of his books.[^7]
- **Sarah Silverman**, an American comedian, writer, and actress. The complaint alleges that she owns a registered copyright in her memoir *The Bedwetter: Stories of Courage, Redemption, and Pee*, originally published in 2010.[^7]
- **Christopher Golden**, an American author of horror, supernatural, and fantasy fiction. According to the complaint, Golden resides in Massachusetts and owns registered copyrights in several books, including *Ararat*.[^7]

After the action was consolidated with a related case (*Chabon v. Meta Platforms*) and amended several times, the plaintiff group grew to thirteen authors. In addition to the three original plaintiffs, the consolidated complaint named Ta-Nehisi Coates, Junot Diaz, Andrew Sean Greer, David Henry Hwang, Matthew Klam, Laura Lippman, Rachel Louise Snyder, Lysa TerKeurst, Jacqueline Woodson, and Christopher Farnsworth.[^8][^9] Their works span genres and include Pulitzer Prize winning novels (Diaz's *The Brief Wondrous Life of Oscar Wao* and Greer's *Less*), a Broadway play (Hwang), and nonfiction (Snyder's *No Visible Bruises*).[^8]

The plaintiffs were initially represented by the Joseph Saveri Law Firm, the same firm that filed numerous early AI copyright cases. In September 2024, after Judge Chhabria criticized the conduct of the litigation, the prominent firm Boies Schiller Flexner joined as co-counsel, with David Boies among the new attorneys of record.[^10]

### Defendant

The sole defendant is **Meta Platforms, Inc.**, the parent company of Facebook, Instagram, and WhatsApp, and the developer of the open-weight [Llama 2](/wiki/llama_2), [Llama 3](/wiki/llama_3), and [Llama 4](/wiki/llama_4) families of large language models. Meta has been represented by Cooley LLP.[^11]

### Court and judge

The case is being heard in the U.S. District Court for the Northern District of California, sitting in San Francisco. Judge **Vince Chhabria**, a 2014 Obama appointee, presides. Chhabria has handled several other high-profile cases (including litigation over Roundup weed killer) and is widely regarded as an unusually pointed and skeptical jurist.[^1][^12]

## Filing of the complaint (July 2023)

The original class action complaint was filed on **July 7, 2023**, in the Northern District of California by Kadrey, Silverman, and Golden on behalf of themselves and a putative class of similarly situated authors.[^7][^13] It alleged six causes of action:

1. Direct copyright infringement under 17 U.S.C. § 501.
2. Vicarious copyright infringement.
3. Violation of the Digital Millennium Copyright Act (DMCA) for removal of copyright management information, 17 U.S.C. § 1202(b).
4. Unfair competition under California's Unfair Competition Law.
5. Unjust enrichment.
6. Negligence.[^7]

The complaint's core factual allegation was that Meta had copied many of the plaintiffs' copyrighted books, without permission or compensation, and used them as training data for Llama. The plaintiffs identified the **Books3** dataset, a corpus of nearly 200,000 books compiled by AI researcher Shawn Presser and distributed as part of [EleutherAI](/wiki/eleutherai)'s [Pile](/wiki/the_pile) dataset, as a likely source. Books3 itself is widely reported to have been derived from the shadow library Bibliotik, a torrent-based site hosting copyrighted e-books.[^14][^15]

A parallel lawsuit, *Silverman v. OpenAI*, was filed against [OpenAI](/wiki/openai) on the same day. The two suits raised closely related theories but proceeded on separate tracks.[^16]

## Motion to dismiss ruling (November 2023)

Meta moved to dismiss the complaint. On November 20, 2023, Judge Chhabria granted the motion in substantial part. The court allowed the plaintiffs' core claim of direct copyright infringement (i.e., the unauthorized copying of their books into Meta's training corpus) to proceed but dismissed most ancillary theories.[^17][^18]

Chhabria characterized one of the plaintiffs' more aggressive theories, that the Llama models themselves are infringing derivative works of every book they were trained on, as "nonsensical." The court reasoned that an LLM consists of weights and parameters expressing abstract mathematical relationships and is not a recasting or adaptation of any particular author's expression. The court also rejected the theory that every model output is an infringing derivative without specific allegations of substantially similar outputs.[^17][^18]

Most ancillary claims were dismissed with leave to amend; the negligence claim was dismissed with prejudice. The plaintiffs subsequently filed amended and consolidated complaints, ultimately culminating in a Third Amended Consolidated Complaint filed January 21, 2025, after the case had been consolidated with the related *Chabon* action.[^8][^19]

## Discovery and the LibGen revelations (2024 through early 2025)

Discovery in Kadrey produced an unusually rich body of internal Meta documents bearing on the company's knowledge that material in its training data had been obtained from pirate sources. The revelations attracted extensive press coverage and are widely regarded as among the most consequential factual disclosures in any pending AI copyright case.

### Meta's use of shadow libraries

Documents unsealed during the proceedings indicated that Meta downloaded books in bulk from multiple shadow libraries, principally **LibGen** (Library Genesis), **Anna's Archive**, and **Z-Library**. Plaintiffs alleged, based on internal Meta records, that Meta torrented approximately 81.7 terabytes of data from these libraries to use as training material for Llama.[^20][^21]

In February 2025, Ashley Belanger of *Ars Technica* reported on unsealed exhibits showing the scale of Meta's downloads and quoting internal messages in which Meta engineers acknowledged the legal sensitivity of the activity.[^20] *The Register* and *Rolling Stone* also covered the disclosures.[^22][^23]

### Internal communications

Court filings cited a series of internal Meta communications expressing concern over the legality and ethics of using pirated material. According to the filings, one engineer wrote that "torrenting from a corporate laptop doesn't feel right." Another internal exchange flagged that "using pirated material should be beyond our ethical threshold." Meta employees also discussed avoiding use of corporate IP addresses while accessing the shadow libraries.[^21][^24]

Plaintiffs further alleged, again citing internal documents, that a Meta engineer (identified in pleadings as Nikolay Bashlykov) acknowledged stripping copyright management information from LibGen-sourced files before they were used in training. This evidence underlay the plaintiffs' DMCA § 1202(b) claim.[^21][^25]

### Escalation to Zuckerberg

Perhaps the most widely quoted internal document was an email cited in court filings indicating that Meta's decision to proceed with LibGen as a training source was "escalated to MZ," meaning Meta CEO Mark Zuckerberg. According to the filings, an executive (Sony Theakanath, director of product management) wrote that after escalation to MZ, the generative-AI team had "been approved to use LibGen" for Llama, with the further caveat that Meta would not publicly disclose its use of the dataset.[^21][^24]

### Zuckerberg deposition

Mark Zuckerberg was deposed in the case. According to filings and news reports describing the testimony, Zuckerberg stated when asked about the activity that the type of conduct described in the complaint would raise "lots of red flags" and "seems like a bad thing." Asked specifically about LibGen, Zuckerberg testified that he had "not really heard of" the dataset.[^23][^24] In a related discussion of training data sources, he referenced Meta's own platforms and YouTube as alternative content reservoirs.[^26]

The discovery record also reflected a January 2025 dispute in which the plaintiffs alleged that Meta produced unusually incriminating internal documents only hours before the close of fact discovery, prompting motion practice over additional disclosures.[^21][^24]

## Meta's defense: fair use

Meta's principal defense was that its copying of copyrighted books for the purpose of training Llama constituted **fair use** under 17 U.S.C. § 107. Meta argued that:

- The use of the books was **highly transformative**: the books were not copied to be read or distributed in their original form, but to extract statistical patterns of language that could be used to power a general-purpose language model with diverse downstream applications.
- The use produced a **new product (the Llama model)** whose purpose differs fundamentally from the entertainment, education, or aesthetic experience that the books were designed to provide.
- Plaintiffs had not proven any cognizable **market harm**: Meta argued that Llama does not regurgitate the plaintiffs' books and does not substitute for them in the marketplace.[^4][^27]

Meta also argued that its alleged downloading from shadow libraries should not change the fair-use analysis because the relevant "use" was the training itself, not the antecedent acquisition. The plaintiffs vigorously contested this framing, arguing that knowing acquisition from pirate sources should weigh against fair use under the "bad faith" prong of the first fair-use factor.[^4]

## The June 25, 2025 summary judgment ruling

On June 25, 2025, Judge Chhabria issued a 40-page order denying the plaintiffs' motion for partial summary judgment and granting Meta's cross-motion for partial summary judgment on the reproduction-based copyright claim.[^3][^4] The ruling addressed the cross-motions on the central training-use issue.

### Fair use analysis

Applying the four-factor fair-use test, Chhabria held:

- **Factor one (purpose and character of the use).** The use was "highly transformative." The court characterized the purpose of training a [large language model](/wiki/large_language_model) as fundamentally different from the purpose of the books themselves, which is "to be read for entertainment or education." The court declined to penalize Meta heavily for its pirate-source acquisition, treating the downloading and the training as an integrated transformative process.[^3][^4]
- **Factor two (nature of the copyrighted work).** The court gave this factor limited weight, treating it as a routine consideration in fair-use cases involving expressive works.[^4]
- **Factor three (amount and substantiality).** The court acknowledged that Meta had copied entire books but explained that whole-work copying is often necessary for training and does not by itself defeat fair use.[^4]
- **Factor four (effect on the market for or value of the copyrighted work).** This factor was the decisive one. The court accepted that AI-generated outputs could in principle cause market harm to authors but found that the plaintiffs had not produced sufficient evidence on the record before the court that Llama caused, or threatened, any specific market harm to the named plaintiffs' books.[^3][^4]

### The "wrong arguments" passage

Chhabria's opinion was striking for its candor about the limits of the ruling. In a passage that became one of the most quoted statements in the early AI copyright case law, the court wrote:

> "This ruling does not stand for the proposition that Meta's use of copyrighted materials to train its language models is lawful. It stands only for the proposition that these plaintiffs made the wrong arguments and failed to develop a record in support of the right one."[^3][^28]

The court explained that the plaintiffs had not adequately pursued or supported a **market dilution** theory. Under that theory, an AI model that produces large quantities of content similar in style or genre to a given author's work could indirectly substitute for and dilute the market for the original works, even without copying any particular passage verbatim. Chhabria suggested that plaintiffs in future cases could very well prevail under such a theory if they presented adequate evidence.[^3][^28]

The opinion also contained pointed observations about Meta. Chhabria noted that AI companies generating "billions, even trillions of dollars" should generally be able to compensate copyright holders if their training requires the holders' works. He cautioned that in many circumstances "it will be illegal to copy copyright-protected works to train generative AI without permission" and that companies "will generally need to pay copyright holders."[^3][^4]

### DMCA ruling

In a separate order issued shortly after the principal opinion, the court granted summary judgment for Meta on the plaintiffs' DMCA § 1202(b) claim concerning the alleged removal of copyright management information. The court reasoned that because the underlying training copying was fair use and therefore not infringement, there was no underlying infringement that the alleged removal of CMI could have facilitated or concealed, leaving the statutory predicate for the DMCA claim unmet.[^25][^29]

### Remaining live claims

The court emphasized that it was deciding only the reproduction-based copyright claim arising from Meta's training use. Neither side had moved for summary judgment on the plaintiffs' separate theory that Meta had violated the authors' distribution right by uploading book files (leeching or seeding) during the torrenting process. That distribution claim remained a live issue in the case.[^4][^30]

## Aftermath and reactions

### Authors Guild and plaintiff-side commentary

The Authors Guild characterized the ruling as "a technical win" for Meta on procedural and evidentiary grounds rather than a substantive endorsement of AI training on copyrighted works. CEO Mary Rasenberger emphasized in interviews and a Guild statement that the opinion in fact endorsed the legal premise that unauthorized AI training can be infringing in many circumstances, and that the judge had expressed dim views of Meta's piracy.[^28]

The Copyright Alliance, an industry group representing rights holders, was similarly critical of how the ruling had been characterized in popular media, arguing that Chhabria's opinion contained important caveats that had been underemphasized.[^31]

### Meta and AI-industry commentary

Meta hailed the ruling as a vindication of fair use as applied to AI training. Law firms representing technology companies, including Goodwin Procter, Skadden, and Perkins Coie, published client alerts portraying the ruling as a significant data point favoring AI developers, while noting Chhabria's market-dilution caveats and warning clients that future cases on better records could come out differently.[^4][^27][^29]

### Post-ruling proceedings

In the months following the ruling, the parties continued to litigate the remaining distribution-rights claim. On July 9, 2025, the parties filed a Joint Case Management Statement addressing how to proceed on the distribution issue and on a number of unresolved scheduling and amendment questions.[^30] Plaintiffs moved to amend their complaint to add contributory infringement and additional uploading-based claims; Judge Chhabria characterized the delay in seeking amendment as "inexcusable" but invited supplemental briefing.[^32]

By early 2026, the court had issued a new scheduling order setting an extended timeline for the distribution-claim phase. Under that schedule, expert reports are due in autumn 2026, summary judgment briefing is set for late 2026 through early 2027, and the hearing on summary judgment on the distribution claim is scheduled for **February 25, 2027** in San Francisco.[^33] In a March 25, 2026 order, the court granted plaintiffs leave to amend their complaint on the contributory and distribution-related theories.[^33]

### Appeal status

As of May 2026, the June 25, 2025 ruling on the training/reproduction claim has not been finally appealed to the U.S. Court of Appeals for the Ninth Circuit, because the district court has not entered a final judgment. With the distribution claim still pending in the trial court, the reproduction ruling remains an interlocutory disposition that is not yet ripe for an appeal as of right. Plaintiffs and commentators have publicly indicated an intention to appeal the fair-use ruling once the case becomes final, but no Ninth Circuit briefing schedule has been set in connection with the Kadrey training ruling as of May 2026.[^33]

## Comparison with related cases

### Bartz v. Anthropic

Two days before the Kadrey ruling, on June 23, 2025, Judge William Alsup (also of the Northern District of California) issued a summary judgment ruling in [Bartz v. Anthropic](/wiki/bartz_v_anthropic). Alsup found that [Anthropic](/wiki/anthropic)'s training of its Claude models on legally acquired books was "exceedingly transformative" fair use, but held separately that Anthropic's earlier downloading and retention of a "central library" of millions of pirated books was *not* fair use because it was a non-transformative use untethered to the actual training.[^5][^34]

Chhabria and Alsup thus reached opposite conclusions on the legality of acquiring training materials from pirate sources. Alsup treated the act of pirate acquisition as a discrete and non-transformative use. Chhabria, by contrast, viewed the acquisition as part of an integrated transformative chain leading to model training. Chhabria also expressly criticized Alsup's emphasis on transformativeness, calling for closer attention to market harm as the controlling factor in AI fair-use analysis.[^5][^34]

Bartz was subsequently settled by Anthropic in 2025, with reports describing a class-wide settlement following class certification on the piracy claims; the procedural posture of Bartz therefore differs materially from Kadrey.[^35]

### Concord Music Group v. Anthropic

[Concord Music Group v. Anthropic](/wiki/concord_v_anthropic), filed by major music publishers, raised fair-use and copyright issues in the context of song lyrics rather than books. Like Kadrey, it raised questions about whether AI training on copyrighted text constitutes fair use, but on a different factual record and against a different defendant.[^36]

### New York Times v. OpenAI

In [New York Times v. OpenAI](/wiki/new_york_times_v_openai), filed in late 2023 in the Southern District of New York, *The New York Times* alleged that OpenAI and Microsoft trained ChatGPT on Times articles and that the model could be induced to reproduce substantial portions of those articles. That case differs from Kadrey in two important respects: it concerns periodical journalism rather than books, and it includes detailed evidence of alleged verbatim outputs (regurgitation) directly tied to specific copyrighted works, an evidentiary record that Chhabria specifically noted the Kadrey plaintiffs had failed to develop.[^37]

### Significance across cases

Taken together, the Kadrey, Bartz, Concord, and New York Times cases represent the first generation of judicial reasoning about the application of U.S. fair-use doctrine to generative AI training. Industry commentators and academic observers have widely characterized Kadrey as the most cautious of the early "AI-favorable" rulings: while Meta won on the existing record, the opinion expressly invited plaintiffs in future cases to mount stronger market-dilution and pirate-acquisition challenges.[^5][^6][^27]

## Status as of May 2026

As of May 19, 2026:

- The June 25, 2025 summary judgment ruling for Meta on the reproduction-based training claim stands as the law of the case in the trial court.[^3]
- The June 27, 2025 ruling for Meta on the DMCA § 1202(b) claim likewise stands.[^25]
- The plaintiffs' **distribution claim**, premised on Meta's alleged uploading (seeding and leeching) of pirated book files during torrenting, remains pending in the district court. A summary judgment motion hearing on that claim is scheduled for February 25, 2027.[^33]
- Plaintiffs have been granted leave to amend their complaint to include contributory infringement and additional uploading-based theories.[^33]
- No final judgment has been entered. No appeal has yet been taken to the Ninth Circuit on the training/fair-use ruling.[^33]

The case continues to be closely followed because of its precedential weight on the fair-use question, its unusually detailed record concerning Meta's use of pirate sources, and Judge Chhabria's explicit invitation to future plaintiffs to develop market-dilution theories.

## References

[^1]: U.S. District Court for the Northern District of California, "Kadrey et al v. Meta Platforms, Inc., 3:23-cv-03417," CourtListener docket. https://www.courtlistener.com/docket/67569326/kadrey-v-meta-platforms-inc/ . Accessed 2026-05-19.

[^2]: U.S. Government Publishing Office, "Kadrey et al v. Meta Platforms, Inc.," govinfo content details. https://www.govinfo.gov/app/details/USCOURTS-cand-3_23-cv-03417 . Accessed 2026-05-19.

[^3]: Order Denying Plaintiffs' Motion for Partial Summary Judgment and Granting Defendant's Cross-Motion for Partial Summary Judgment, Kadrey et al. v. Meta Platforms, Inc., No. 3:23-cv-03417-VC, Document 598 (N.D. Cal. June 25, 2025), Justia. https://law.justia.com/cases/federal/district-courts/california/candce/3:2023cv03417/415175/598/ . Accessed 2026-05-19.

[^4]: Goodwin Procter LLP, "Northern District of California Judge Rules That Meta's Training of AI Models Is Fair Use," June 2025. https://www.goodwinlaw.com/en/insights/publications/2025/06/alerts-practices-aiml-northern-district-of-california-judge-rules . Accessed 2026-05-19.

[^5]: Debevoise & Plimpton LLP, "Anthropic and Meta Decisions on Fair Use," June 2025. https://www.debevoise.com/insights/publications/2025/06/anthropic-and-meta-decisions-on-fair-use . Accessed 2026-05-19.

[^6]: Manatt, Phelps & Phillips, "Making Sense of the First Two Often Contradictory, Sometimes Confounding Gen AI Fair Use Rulings," 2025. https://www.manatt.com/insights/newsletters/client-alert/making-sense-of-the-first-two-often-contradictory-sometimes-confounding-gen-ai-fair-use-rulings . Accessed 2026-05-19.

[^7]: Complaint, Kadrey et al. v. Meta Platforms, Inc., No. 3:23-cv-03417 (N.D. Cal. filed July 7, 2023). https://llmlitigation.com/pdf/03417/kadrey-meta-complaint.pdf . Accessed 2026-05-19.

[^8]: Third Amended Consolidated Complaint, Kadrey et al. v. Meta Platforms, Inc., No. 3:23-cv-03417-VC (N.D. Cal. filed Jan. 21, 2025). https://www.courthousenews.com/wp-content/uploads/2025/02/kadrey-vs-meta-third-amended-complaint.pdf . Accessed 2026-05-19.

[^9]: Order Consolidating Kadrey and Chabon, Kadrey et al. v. Meta Platforms, Inc., No. 3:23-cv-03417-VC (N.D. Cal. 2024). https://files.lbr.cloud/public/2024-07/Order%20consolidating%20Kadrey.pdf?VersionId=I.esXv_l1kseUn20fvb59QW5Bh4.jp9_ . Accessed 2026-05-19.

[^10]: Law.com (The Recorder), "Chastised by Judge, Authors' Lawyers Bring Boies Schiller Into Meta AI Copyright Suit," Sept. 24, 2024. https://www.law.com/therecorder/2024/09/24/chastised-by-judge-authors-lawyers-bring-boies-schiller-into-meta-ai-copyright-suit/ . Accessed 2026-05-19.

[^11]: Cooley LLP, "Cooley Secures Early Victory for Meta Platforms in AI Class Action," Dec. 8, 2023. https://www.cooley.com/news/coverage/2023/2023-12-08-cooley-secures-early-victory-for-meta-platforms-in-ai-class-action . Accessed 2026-05-19.

[^12]: FindLaw, "Kadrey v. Meta Platforms Inc. (2025)." https://caselaw.findlaw.com/court/us-dis-crt-n-d-cal/117422847.html . Accessed 2026-05-19.

[^13]: Justia, "Kadrey et al v. Meta Platforms, Inc., 3:2023cv03417 docket." https://dockets.justia.com/docket/california/candce/3:2023cv03417/415175 . Accessed 2026-05-19.

[^14]: Loeb & Loeb LLP, "Richard Kadrey v. Meta Platforms, Inc.," December 2023. https://www.loeb.com/en/insights/publications/2023/12/richard-kadrey-v-meta-platforms-inc . Accessed 2026-05-19.

[^15]: Mogin Law LLP, "Authors Sue Meta Platforms Over Copyright Infringement in AI Training Dataset." https://moginlawllp.com/authors-sue-meta-platforms-over-copyright-infringement-in-ai-training-dataset/ . Accessed 2026-05-19.

[^16]: The Fashion Law, "Sarah Silverman Among Authors Suing Meta, OpenAI for Copyright Infringement." https://www.thefashionlaw.com/sarah-silverman-among-authors-suing-meta-openai-for-copyright-infringement/ . Accessed 2026-05-19.

[^17]: Skadden, Arps, Slate, Meagher & Flom LLP, "Court Grants Motion To Dismiss in Kadrey AI Training Data Case," November 2023. https://www.skadden.com/insights/publications/2023/11/court-grants-motion-to-dismiss . Accessed 2026-05-19.

[^18]: Vanderbilt Law School, "Meta Faces Copyright Claims Over AI Training Data: Survives Motion to Dismiss Stage." https://law.vanderbilt.edu/meta-faces-copyright-claims/ . Accessed 2026-05-19.

[^19]: Justia Dockets, "ORDER granting Motion to Dismiss for Kadrey et al v. Meta Platforms, Inc." https://docs.justia.com/cases/federal/district-courts/california/candce/3:2023cv03417/415175/56 . Accessed 2026-05-19.

[^20]: Techmeme summary of Ashley Belanger, Ars Technica, "Kadrey v. Meta: unsealed emails show Meta allegedly torrented 81.7TB+ of data across multiple shadow libraries," Feb. 7, 2025. https://www.techmeme.com/250207/p1 . Accessed 2026-05-19.

[^21]: Chat GPT Is Eating the World, "Meta, Mark Zuckerberg suffer disastrous week in AI copyright lawsuit by book authors," Jan. 10, 2025. https://chatgptiseatingtheworld.com/2025/01/10/meta-mark-zuckerberg-suffers-disastrous-week-in-ai-copyright-lawsuit-by-book-authors/ . Accessed 2026-05-19.

[^22]: The Register, "Meta may have illegally removed copyright info in AI corpus," Mar. 11, 2025. https://www.theregister.com/2025/03/11/meta_dmca_copyright_removal_case/ . Accessed 2026-05-19.

[^23]: Rolling Stone, "Zuckerberg Appeared to Know Meta Trained AI on Pirated Library." https://www.rollingstone.com/culture/culture-news/ai-meta-pirated-library-zuckerberg-1235235394/ . Accessed 2026-05-19.

[^24]: Redact.dev, "Meta Court Documents Reveal Ethical Concerns in AI Training Practices." https://redact.dev/blog/meta-ai-zuckerberg-pirated-books-training-controversy . Accessed 2026-05-19.

[^25]: Perkins Coie LLP, "Court Sides With Meta on Fair Use and DMCA Questions, but Leaves Door Open for Future Challenges," 2025. https://perkinscoie.com/insights/update/court-sides-meta-fair-use-and-dmca-questions-leaves-door-open-future-challenges . Accessed 2026-05-19.

[^26]: AutoGPT.net, "Zuckerberg References YouTube in Ongoing AI Copyright Case." https://autogpt.net/zuckerberg-references-youtube-in-ongoing-ai-copyright-case/ . Accessed 2026-05-19.

[^27]: Akin Gump Strauss Hauer & Feld, "Second District Court Rules AI Training Can Be Fair Use," AI Law and Regulation Tracker. https://www.akingump.com/en/insights/ai-law-and-regulation-tracker/second-district-court-rules-ai-training-can-be-fair-use . Accessed 2026-05-19.

[^28]: IPWatchdog, "Judge Says Authors Made the Wrong Arguments in Ruling for Meta on Fair Use," June 26, 2025. https://ipwatchdog.com/2025/06/26/judge-says-authors-made-wrong-arguments-ruling-meta-fair-use/id=189857/ . Accessed 2026-05-19.

[^29]: Loeb & Loeb LLP, "Kadrey v. Meta Platforms, Inc.," July 2025. https://www.loeb.com/en/insights/publications/2025/07/kadrey-v-meta-platforms-inc . Accessed 2026-05-19.

[^30]: Joint Case Management Statement, Kadrey v. Meta Platforms, Inc., No. 3:23-cv-03417-VC, Document 605 (N.D. Cal. filed July 8, 2025). https://chatgptiseatingtheworld.com/wp-content/uploads/2025/07/Kadrey-v-Meta-Joint-Case-Management-Statement-July-9-2025.pdf . Accessed 2026-05-19.

[^31]: Copyright Alliance, "Kadrey v. Meta Decision: Did Meta Just Win the Battle, But Lose the War?" https://copyrightalliance.org/kadrey-v-meta-decision/ . Accessed 2026-05-19.

[^32]: McKool Smith, "AI Infringement Case Updates: February 24, 2026." https://www.mckoolsmith.com/newsroom-ailitigation-53 . Accessed 2026-05-19.

[^33]: Chat GPT Is Eating the World, "Kadrey v. Meta gets scheduling order. Summary judgment motion hearing for distribution claim won't be heard until Feb. 25, 2027," Mar. 27, 2026. https://chatgptiseatingtheworld.com/2026/03/27/kadrey-v-meta-gets-scheduling-order-summary-judgment-motion-hearing-for-distribution-claim-wont-be-heard-until-feb-25-2027/ . Accessed 2026-05-19.

[^34]: Norton Rose Fulbright, "Two US decisions find that reproducing works to train large language models is fair use - Part 2: Kadrey v Meta." https://www.nortonrosefulbright.com/en/knowledge/publications/29109e7a/two-us-decisions-find-that-reproducing-works-to-train . Accessed 2026-05-19.

[^35]: Norton Rose Fulbright, "Bartz v. Anthropic: Settlement reached after landmark summary judgment and class certification," September 2025. https://www.insidetechlaw.com/blog/2025/09/bartz-v-anthropic-settlement-reached-after-landmark-summary-judgment-and-class-certification . Accessed 2026-05-19.

[^36]: Jackson Walker LLP, "Federal Courts Find Fair Use in AI Training: Key Takeaways from Kadrey v. Meta and Bartz v. Anthropic." https://www.jw.com/news/insights-kadrey-meta-bartz-anthropic-ai-copyright/ . Accessed 2026-05-19.

[^37]: Sterne Kessler, "AI IP Year in Review: The Market Harm Dilemma: What Bartz and Kadrey Reveal About Fair Use's Future in Generative AI." https://www.sternekessler.com/news-insights/insights/ai-ip-year-in-review-the-market-harm-dilemma-what-bartz-and-kadrey-reveal-about-fair-use%CA%BCs-future-in-generative-ai/ . Accessed 2026-05-19.